DICKSON v. SAUL (2021)

United States Court of Appeals, Ninth Circuit.2021-02-24No. No. 19-17215

Summary · law.co

Holding. The court affirmed the district court's decision upholding the administrative law judge's denial of disability benefits, finding no legal error and substantial evidentiary support for the judge's weighing of medical opinions and rejection of the claimant's symptom testimony.

Marlene Dickson sought disability insurance benefits under Social Security law, but an administrative law judge denied her application. The district court upheld that denial, and Dickson appealed. The appellate court reviewed whether the denial was supported by substantial evidence and contained no legal errors.

The court found no error in how the administrative law judge weighed competing medical opinions. Although treating physicians' opinions normally receive substantial deference, an administrative law judge may discount them when contradicted by other medical evidence if specific reasons supported by the record are provided. Here, the judge reasonably found the treating physicians' opinions inconsistent with medical records and their own clinical notes. The judge properly gave greater weight to a non-treating physician's opinion that aligned with the medical evidence and Dickson's daily functioning, as well as to examining and non-examining physicians whose findings of mild impairments matched the record.

The court also upheld the judge's rejection of Dickson's testimony about symptom severity. Because Dickson's described daily activities contradicted her claims of disabling symptoms and limitations, the judge had sufficient grounds to discount her testimony without needing to provide additional reasons.

Summary generated by law.co from the public-domain opinion. The opinion text itself is public domain.

Key issues

Weight given to treating physicians' opinions versus non-treating physicians' opinions in disability determinations
Standards for rejecting a treating physician's opinion when contradicted by other medical evidence
Rejection of claimant's symptom testimony based on inconsistency with daily activities

Procedural posture

Dickson appealed the district court's affirmance of an administrative law judge's denial of her Title II Social Security disability insurance benefits application.

Authorities cited

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Opinion · public domain

MEMORANDUM *

Claimant Marlene Dickson appeals from the district courts decision affirming the Commissioners denial of her application for disability insurance benefits under Title II of the Social Security Act. We have jurisdiction under 28 U.S.C. § 1291. “We review the district courts order affirming the ALJs denial of social security benefits de novo, and will disturb the denial of benefits only if the decision contains legal error or is not supported by substantial evidence.” Ford v. Saul, 950 F.3d 1141, 1153–54 (9th Cir. 2020) (internal quotation marks omitted) (quoting Tommasetti v. Astrue, 533 F.3d 1035, 1038 (9th Cir. 2008)).

The Administrative Law Judge (ALJ) did not err in rejecting the assessments of Dicksons treating physicians, Drs. Laura Sherman and Loren Froelich. While a treating physicians opinion generally receives “controlling weight,” see 20 C.F.R. § 404.1527(c)(2), “if the treating doctors opinion is contradicted by another doctor, the ALJ may discount the treating physicians opinion by giving specific and legitimate reasons that are supported by substantial evidence in the record,” Ford, 950 F.3d at 1154 (internal quotation marks and citation omitted). The ALJ offered specific and legitimate reasons to reject Dicksons treating physicians’ opinions. Namely, the ALJ assigned those physicians’ opinions little weight because they were inconsistent with the medical evidence and the physicians’ own notes and this reasoning is supported by substantial evidence in the record.

Additionally, the ALJ did not err in assigning greater weight to the non-treating physicians’ opinions. The ALJ assigned great weight to Dr. Karen Mansfield-Blairs opinion because it was consistent with the medical evidence and Dicksons daily activities. See 20 C.F.R. § 404.1527(c)(4). The ALJ also assigned partial weight to the opinions of examining physicians Drs. Neil Stafford and An Nguyen and the non-examining physician Dr. Elliot Salk because their findings of mild impairments were consistent with the record. Because these conclusions are supported by substantial evidence, the ALJ did not err in assessing these medical opinions.

Finally, the ALJ did not err in discounting Dicksons symptom testimony. If a claimant has shown that an impairment “could reasonably be expected to produce the pain or other symptoms alleged,” the ALJ may reject “testimony about the severity of her symptoms only by offering specific, clear and convincing reasons for doing so.” Lingenfelter v. Astrue, 504 F.3d 1028, 1036 (9th Cir. 2007) (citations omitted). The ALJ concluded that Dicksons described daily activities were inconsistent with her allegations of disabling symptoms and limitations. Because a contradiction between daily activities and alleged limitations is a sufficient basis to reject Dicksons testimony, see Molina v. Astrue, 674 F.3d 1104, 1113 (9th Cir. 2012), we find no error.

AFFIRMED.